Estate of Goelet v. Commissioner
United States Tax Court
In 1960, settlor established a trust, the income of which was payable to his children and the principal of which was distributable to them if they survived the settlor and reached a specific age, otherwise to designated classes of beneficiaries. Settlor retained, as trustee, power to pay or accumulate income and power to distribute principal to his children, thereby terminating the trust and destroying the contingent remainders.
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In 1960, settlor established a trust, the income of which was payable to his children and the principal of which was distributable to them if they survived the settlor and reached a specific age, otherwise to designated classes of beneficiaries. Settlor retained, as trustee, power to pay or accumulate income and power to distribute principal to his children, thereby terminating the trust and destroying the contingent remainders. Held, the retained powers prevented the transfer in trust from being a completed gift under sec. 2511(a), I.R.C. 1954; held, further, no part of the transfer was made…
1Opinion of the Court
Estate of Henry Goelet, Deceased, Henriette Goelet, Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent; Henriette Goelet, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Goelet v. Commissioner
Docket Nos. 6357-66, 6358-66
United States Tax Court
51 T.C. 352; 1968 U.S. Tax Ct. LEXIS 16;
December 11, 1968, Filed
Decisions will be entered for petitioners.
In 1960, settlor established a trust, the income of which was payable to his children and the principal of which was distributable to them if they survived the settlor and reached a specific age, otherwise to…
2Cases cited13 opinions
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Robinette v. HelveringSupreme Court of the United States · 1943
- Commissioner v. Estate of HolmesSupreme Court of the United States · 1946
- Vanderpoel v. . LoewNew York Court of Appeals · 1889
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